...client must utilize the IRS Voluntary Disclosure Practice (VDP) versus civil disclosure pathways, and the severe risks of making a non-willful certification under penalties of perjury when elements of willfulness...
On December 22, 2025, the Internal Revenue Service announced a 90-day public comment period on a proposed revised Voluntary Disclosure Practice (“VDP”). The VDP is a compliance program designed for...
...current VDP has not yet been preliminarily accepted, taxpayers can notify vdp@ci.irs.gov of their intention to switch to the proposed VDP. If the application to the current VDP has been...
...Disclosure Practice (VDP): If the failure was “willful” (a voluntary, intentional violation of a known legal duty) the formal VDP provides a path to avoid criminal prosecution, though it typically...
...to make a conclusive legal determination on the VDP application form. However, legal counsel remains more important than ever. The VDP is a complex and high-stakes process. Navigating it requires...
...Identifying Barriers to Participation in the VDP While the VDP is intended to offer taxpayers a structured pathway to compliance, changes implemented in 2018 and 2024 have inadvertently created significant...
...stricter deadlines, and full payment of liabilities, the IRS deters taxpayers with genuine intent to resolve past issues via the VDP. Taxpayers must approach the VDP with careful planning, robust...
The IRS’s Voluntary Disclosure Practice (VDP) allows noncompliant taxpayers who have failed to meet their tax obligations to come into compliance and avoid criminal prosecution. Financially, the VDP offers the...
...potential civil litigation, penalties & interest. Under the ERC VDP, if the IRS paid interest on the employer’s ERC refund claim, the employer is not required to repay that interest....
...need to disclose virtual currency transaction federal income tax consequences should avail themselves of this expanded opportunity to report their virtual currencies via the IRS CI VDP and avoid potential...
...not qualify for VDP. Another aspect of voluntary disclosure is that it must be timely as well. To be timely according to the IRS, they have to receive the disclosure...
...Taxpayers with undisclosed foreign income and assets. In 2018 the IRS closed this program and expanded the VDP Program. The new VDP Program is primarily for taxpayers who are considered...
